What is a subrecipient in federal grants

what is a subrecipient in federal grants

Grant Terminology

Mar 18,  · If you are looking for more formal definitions, the Grants Learning Center’s Terminology page defines subrecipient this way: A non-Federal entity that receives a subaward from a pass-through entity to carry out part of a Federal program; but does not include an . Mar 18,  · In such cases, one entity – the one who submitted the grant application – will serve as a pass-through to the partnering entities, which are called subrecipients.

Share Online:. How does an organization determine if federal funding is received under a subrecipient vs. OMB requires subrecipients that meet established expenditure thresholds to obtain a Single Audit, and correctly identifying the relationship under which funds are received is a key component of calculating expenditures.

The following is a list of indicative characteristics that might be helpful for the determination based on the relative responsibilities of both the non-profit organization receiving the funds and the awarding agency providing the funds. The examples provided here are not intended for use as a checklist or to replace the need for professional judgment and separate consideration of each arrangement on its own merits.

How to download videos from wevideo for free who is eligible to receive financial assistance, and which specific type of federal assistance is to be distributed. For example:. Has its performance measured against whether it meets the objectives of the program. Uses the funds to carry out its own program what is a general practice attorney compared to providing goods or services for a program of the awarding entity.

Agreements with subrecipients may take a number of forms, such as subawards, subgrants, subcontracts and subagreements. The form is less important to the examination of a relationship than its substance. Labeling what is a subrecipient in federal grants organization as a subrecipient or contractor vendor in an agreement does not automatically create one type of relationship or the other.

The characteristics of the relationship must always be examined to determine whether the arrangement as a whole has qualities that are more indicative of a subrecipient or vendor relationship. Tips to help taxpayers spot and avoid tax scams. HBL has been providing tax services, accounting services, auditing and attestation services, consulting services, and various other services since Client Portal Make a Payment.

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A state, local government, Indian tribe, institution of higher education (IHE), or nonprofit organization that carries out a Federal award as a recipient or subrecipient. Federal recipient of Federal assistance that passes that assistance, whether in part or in total, to another recipient (known as. pass-through entities and subrecipients, respectively) is responsible to monitor the Federal assistance activities of that subrecipient, as well as assure that they are both complying with laws and regulations. Oct 07,  · The Subrecipient: Determines who is eligible to receive financial assistance, and which specific type of federal assistance is to be distributed.

Concept of Substantive Work. Sponsored research awards made to WMU are generally conducted within the physical boundaries of the institution.

On occasion, substantive programmatic work is carried out by one or several institution s that are made responsible for a portion of a project awarded to WMU. The concept of substantive work conducted by a third party is defined as follows:.

Distinction between a Subrecipient and a Contractor. WMU, as the pass-through entity, must make a case-by-case determination whether each agreement it makes for the disbursement of Federal funds casts the party receiving the funds in the role of a subrecipient or a contractor.

According to OMB Uniform Guidance, characteristics which support the classification of the non-Federal entity as a subrecipient include, when the non-Federal entity:. Characteristics indicative of a procurement relationship between the non-Federal entity and a contractor are when the non-Federal entity receiving the Federal funds:.

While an external entity may be classified as a contractor, it is still subject to compliance rules and regulations, including those that govern the usage of human or animal subjects and select agents.

Preparing Proposals with Outgoing Subawards A WMU investigator who plans to include another institution to undertake responsibility for a substantive portion of the programmatic effort described in a proposal must provide a number of documents from the proposed subrecipient institution well in advance of proposal submission. At a minimum, these documents include:. Risk Assessment The Office of the Vice President for Research is responsible for conducting subrecipient risk assessments on behalf of the University.

Subrecipient Compliance and Assurance. As the prime recipient of an award which includes one or more outgoing subawards to other entities, the University has the responsibility for ensuring that all research under the prime award is conducted and administered in compliance with sponsor requirements and University policies. Standard Terms in a Subaward.

A subaward will generally include terms and conditions that address the following as appropriate Note: This list is not all inclusive. Subawards issued under a federal prime award will include the following information as required by OMB Uniform Guidance :. Such factors to consider in making the evaluation may include:.

Depending upon the assessment of risk posed by the subrecipient, the following monitoring tools may be useful to ensure proper accountability and compliance with program requirements and achievement of performance goals. The Principal Investigator is responsible for reviewing invoices received from subawardees to ensure that expenditures are reasonable in the context of work performed and to assure that all required progress repor or deliverable are up-to-date, as required by the statement of work or terms of the subaward.

The review includes completing the Subrecipient Invoice Review Form prior to the invoice being paid. Grants and Contracts will review the Federal Audit Clearinghouse Harvester for each subrecipient entity nad, if necessary, request a copy of the most recent audit report for the subrecipient entity and review any findings.

The subawards will be tracked in a subaward database to monitor and review each subrecipient. Early Termination of a subrecipient agreement may occur for a number of reasons, all of which may be problematic. Reasons for early termination include, but are not limited to:. The subrecipient agreement must authorize early termination and specify the conditions.

In early termination, the sponsor usually still requires the submission of all reports. Therefore, closeout procedures will be very similar, if not identical, to the procedures followed if the project had continued to the projected termination date.

All subrecipient files must be retained for a minimum of 3 years after submission of final expenditure to prime sponsor. Unless the prime awarding agency has a different record retention requirement. Logistical Services Purchasing Policies and Procedures.

Downloadable version. Skip to main content. Subrecipient Monitoring Procedures. Effective Date: Aug. Background 1. The concept of substantive work conducted by a third party is defined as follows: 1. Project activities with a primary purpose of the research program which, for whatever reason, are not conducted at the University. These activities constitute a significant portion of the research program and require the leadership and direction of a responsible investigator located at the work site on the cooperating entity.

A subrecipient may also be a recipient of other Federal awards directly from a Federal awarding agency. The term as used in this part does not include a legal instrument, even if the non-Federal entity considers it as a contract, when the substance of the transaction meets the definition of a Federal award or subaward.

According to OMB Uniform Guidance, characteristics which support the classification of the non-Federal entity as a subrecipient include, when the non-Federal entity: 1. Determines who is eligible to receive what Federal assistance; 1. Has its performance measured in relation to whether objectives of a Federal program were met; 1. Has responsibility for programmatic decision making; 1. Is responsible for adherence to applicable Federal program requirements specified in the Federal award; and 1.

In accordance with its agreement, uses the Federal funds to carry out a program for a public purpose specified in authorizing statute, as opposed to providing good or services for the benefit of the pass-through entity.

Characteristics indicative of a procurement relationship between the non-Federal entity and a contractor are when the non-Federal entity receiving the Federal funds: 1. Provides the goods and services within normal business operations; 1. Provides similar goods or services to many different purchasers; 1. Normally operates in a competitive environment; 1.

Provides good or services that are ancillary to the operation of the Federal program; and 1. Is not subject to compliance requirements of the Federal program as a result of the agreement. Subrecipient Selection and Review 2.

At a minimum, these documents include: 2. Evidence of commitment to participate in the project and abide by all the associated terms and conditions; 2. Detailed budget and budget justification. The Subrecipient Commitment Form requests a variety of information regarding the financial status of the proposed subrecipient entity. In general, the timing of this questionnaire will normally occur at the time of proposal submission. In rare instances, WMU may determine that the risk of entering into a subaward with the proposed entity is excessive and not move forward with executing the agreement.

Negotiating and Executing Subrecipient Agreements 3. Implementation of any appropriate and necessary risk mitigation strategies; 3.

Financial terms and conditions including: cost reimbursement, billing requirements, and payment terms; 3. Ownership of intellectual property and data; 3. Certification of invoices that costs conform to conditions of allowability and support the performance of work. Subawards issued under a federal prime award will include the following information as required by OMB Uniform Guidance : 3.

Federal Award Identification 3. Subrecipient name; 3. Federal Award Date; 3. Amount of Federal Funds Obligated by this action; 3. Total Amount of Federal Funds Obligated to the subrecipient; 3.

Total Amount of the Federal Award; 3. Indirect cost rate for the Federal award. Appropriate terms and conditions concerning closeout of the subaward. Reviewing financial and programmatic reports as required by the Subaward; 4. Issuing a management decision for audit findings pertaining to the Federal award as required; 4.

Considering taking enforcement action against noncompliant subrecipients. Such factors to consider in making the evaluation may include: 4. The results of previous audits including whether or not the subrecipient receives a Single Audit; 4. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of Federal awarding agency monitoring. Provide subrecipients with training and technical assistance on program-related matters; 4.

Arranging for agreed-upon-procedures engagements. Subrecipient Invoice Review and Approval 5. Responsible Offices 6. Principal Investigator, Departmental Staff responsible for: 6. Subaward Invoice Review and Approval 6. Review subaward expenses for allowability 6. Monitoring technical aspects of the project 6. Monitor technical report requirements 6. Office of Research and Innovation 6.

Prequalifying Subrecipient Questionnaire 6. Proposal Development 6. Subaward Execution 6. Risk Assessment Questionnaire 6. Grants and Contracts 6. Mini Audit Questionnaire 6. Annual Financial Monitoring 6. Review subaward expenses for allowability 7.

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